Privacy Policy

Personal Data Protection Policy

FLEXCEED Co., Ltd. (hereafter referred to as “the Company”) recognizes its social responsibility to ensure thorough protection of personal data in line with the Company’s Personal Data Protection Policy. To ensure that the Website user personal data that the Company utilizes in its business operations will continue to be handled appropriately and safely in the future, this Personal Data Protection Policy has been drawn up as a code of behavior that all employees are required to comply with; the Company will strive to ensure thorough compliance with this Policy.

1.

When obtaining personal data, the Company will make clear in advance the purpose for which the data will be used, and whether the data will be made available for use. The data will only be used with the agreement of the individual concerned, and will be used in an appropriate manner within the scope of the intended purpose; measures will be put in place to prevent the data from being used for purposes other than the intended purpose.

2.

If the Company entrusts the handling of personal data obtained using the measures noted in the previous paragraph to a third party, in part or in whole, or if it provides personal data to a third party, it will select a third party that meets thorough personal data protection standards, and will take appropriate measures through the signing of contracts, etc.

3.

To ensure compliance with all laws, government guidelines, and other regulations relating to personal data protection, in relation to all personal data utilized in the Company’s business operations, the Company has formulated, and makes appropriate use of, a Personal Data Protection Management System based on Japan Industrial Standard Personal Information Management System - Requirements (JIS Q 15001).

4.

The Company will take reasonable safety measures and corrective measures in relation to the risk of improper accessing of personal data and the risk that personal data may be lost, damaged, altered without authorization, disclosed without authorization, etc.

5.

The Company will respond promptly to requests by individuals to have their own personal data disclosed, corrected or deleted, or to have the use of such data terminated, etc. (Inquiries, complaints and queries regarding the handling of personal data should be directed to the contact address given below).

6.

The Company will continue to adjust and improve the Personal Data Protection Management System on an ongoing basis.

The procedures followed in response to a request, in relation to personal data held by the Company, from the individual to which the personal data apply or their agent, etc., for notification of purpose of use, disclosure, correction, addition, deletion, cessation of use, or cessation of provision to third parties (hereafter referred to as “Requests for Disclosure etc.”) are as noted below:

1.

Address to which Requests for Disclosure etc. should be directed:

Department of General Affairs

FLEXCEED Co., Ltd.

6707-1 To, Naka-shi, Ibaraki 311-0122

2.

Documents that can be sent by post:

The following types of documents should be sent to the address noted above under “Address to which Requests for Disclosure etc. should be directed” (the sender is responsible for paying postage on items sent to the Company):

• Notification and disclosure regarding purpose of use (a charge will be made):

Request for disclosure of purpose of use of personal data

• Correction of, addition to or deletion of content (no charge will be made):

Request for correction etc. of personal data

• Cessation of use, elimination, or cessation of provision to third parties (no charge will be made):

Request for cessation of use, etc. of personal data

3.

Documents required to verify the identity of the person concerned:

At least two (2) of the following: Driver’s license, passport, transcript of Family Register, Health Insurance participation certificate, National Pension book, or other official document sufficient to verify identity.

4.

Request for Disclosure etc. made by an agent:

In the case where a Request for Disclosure etc. is made by an agent of the person concerned, then in addition to the documents noted in item 2 above, the following documents (either A or B) must be submitted in the same envelope:

A. In the case of the statutory representative of the person concerned, or of a minor, or of an adult ward:

• Documents sufficient to verify the identity of the statutory agent:

At least two (2) of the following: Driver’s license, passport, transcript of Family Register, Health Insurance participation certificate, National Pension book, or other official document sufficient to verify identity.

・Documents sufficient to verify the possession of statutory agent status:

One (1) of the following: Transcript of Family Register, Health Insurance participation certificate, or Certificate of Registered Matters.

B. In the case of an agent appointed by the person concerned:

• Documents sufficient to verify the identity of the agent:

At least two (2) of the following: Driver’s license, passport, transcript of Family Register, Health Insurance participation certificate, National Pension book, or other official document sufficient to verify identity.

• A letter of attorney in the format specified by the Company

• The Certificate of Seal Impression of the person for whom the agent is acting

In the case of a request for notification of use or request for disclosure (only), the fee noted below (including the postage costs for the Company’s reply) is payable per request. Please include an 800-yen postal fixed-amount money order in the same envelope as the application documents.

*If the amount paid is insufficient to cover the fee, or if the payment is not included in the same envelope as the application documents, the applicant will be notified of this; if the applicant fails to make payment in full within the specified time limit, the request for disclosure will be deemed not to have been made.

6.

Method of reply to Requests for Disclosure etc.:

Reply will be made in writing to the address of the person concerned, as noted in the request.

7.

Purpose of use of personal data obtained in relation to Requests for Disclosure etc.:

Personal data obtained as a result of a Request for Disclosure etc. will be used only within the scope necessitated by the Request for Disclosure etc.

The documents submitted will be preserved for three (3) years after the completion of the reply to the Request for Disclosure etc., after which they will be destroyed.

Reasons for Non-disclosure of Personal Data Subject to Disclosure

In the following cases, personal data will not be disclosed. When the decision has been made not to make disclosure, notification of that decision, and of the reasons for that decision, will be given.

If the decision is made not to make disclosure, the handling fee will not be refunded; your understanding is appreciated.

• Where the identity of the person concerned cannot be verified since the address given in the request is not the same as the address noted on the supporting documents provided for identity verification purposes, or is not the same as the address noted in the Company’s records, etc.

• Where the application is made by an agent, and the agent’s authority to submit the application cannot be verified

• Where there is a deficiency in the documents submitted

• Where the disclosure request does not fall under the category of “personal data subject to disclosure”

• Where there is a risk of harm to the life, health, property etc. of the person concerned or of a third party

• Where there is a risk that disclosure may constitute a significant obstacle to the appropriate exercise of the Company’s business

• Where disclosure would constitute a violation of any law

8.

Revision of the procedures for handling Requests for Disclosure etc.

The content of the procedures for handling Requests for Disclosure etc. may be modified in order to protect customers’ personal data, or in response to changes in the law etc. The currently applicable procedures should be verified each time a Request for Disclosure etc. is made.